I am a licensed insurance professional and variable product salesperson. I have been in the business for over 26 years. I am writing to you concerning the suitability standard and principal review requirements pertaining to the sale of variable annuities contained in NASD proposed Rule 2821. Although the latest NASD proposal includes several amendments made to earlier versions of the proposal, the proposed rule's requirements are redundant, unnecessary, will provide no meaningful additional protection to consumers and will adversely impact my business. In my own experiences, filling out more paperwork does not stop someone who wants to take advantage of our clients. I would rather see more sanctions when it is determined that someone has defrauded a client. Currently, very few are applied to producers of Variable Annuity products.
I urge the SEC to disapprove the proposal.